Oral argument: Oct. 5, 2010
Appealed from: United States Court of Appeals, Ninth Circuit (Nov. 5, 2008)
FEDERALISM, PROCEDURAL DUE PROCESS, DECLARATORY RELIEF, 42 U.S.C. § 1983
In 2001, Craig and Wendy Humphries were arrested on child abuse charges and listed in California's Child Abuse Central Index ("CACI"), which is organized under the Child Abuse and Neglect Reporting Act ("CANRA"). All charges against the Humphrieses were dismissed, and the Humphrieses obtained an order declaring them factually innocent. However, the Humphrieses were unable to contest their listing in the CACI. The Humphrieses sued Los Angeles County pursuant to 42 U.S.C. § 1983 seeking declaratory relief establishing that CANRA and policies related to the CACI are unconstitutional because of the lack of procedures to challenge an individual's inclusion based on a substantiated claim. Los Angeles County argued that as a local government it had no control over CACI procedures because the state government created these policies. The Ninth Circuit sided with the Humphrieses and held that Los Angeles County's liability should be determined according the requirements established in Monell v. Department of Social Services. The Supreme Court must now decide whether claims for declaratory relief against a public entity are subject to the requirements of Monell.
